Calling the case unfair, he has explained that it stems from a difference of opinion and that in 2014 the player declared his income from image rights from the previous three years because that's when he believed it should have been done.

"It has come as a complete surprise and the player feels that it is an injustice," he told Portuguese station SIC Noticias.

"There was no lack of a declaration [of income].

"There was a declaration according to criteria that apparently isn't the criteria the Spanish fiscal authorities like, but there is nothing written in law or in any rulebook that says the player broke the rules."

The lawyer also claimed that there are differences between this case and Lionel Messi's and that the 32-year-old shouldn't be held responsible as he was only following advice.

"Messi's case and those of other players the Spanish authorities have gone after are completely different because these players didn't declare anything," he said in the interview.

"Ronaldo, before suddenly being investigated, declared the part which he thought he had to."

Finally, Lobo Xavier suggested that a case is being brought against his client now because there was a need to do something or else the time for taking action would have expired.

"The timeframe in which it was possible to intervene was almost up," he pointed out.

"In this environment, with processes having been opened against players in Catalonia and with the Spanish tax authorities threatened with a short expiration time, they might have brought this forward in order to hand the responsibility over to other entities and stages of criminal proceedings."

One other point made by Ronaldo's lawyer was the suggestion that he paid more tax using his method than he would have done had he paid the image rights income in each of the three years, instead of as one combined sum.